Most Session Initiation Protocol (SIP)-based desktop telephones fail three fundamental Section 508 accessibility requirements: (1) Caller identification (ID) is not provided in a manner that is accessible to blind users, e.g. by voice [US Code of Federal Regulations, 36 CFR Part 1194.23(e)]; (2) Caller ID is not provided in a manner that is accessible to low-vision users, e.g. very large sans-serif high contrast font, color and background to be user-specified [36 CFR Part 1194.31(b)]; and (3) The visual indication that there is an incoming call is too subtle to attract the attention of deaf users [36 CFR Part 1194.31(c)].
Although these capabilities could be built into the phone itself, it is not economically practical to build a separate “Section 508” series of phones to support the relatively small proportion of people who require those special functions. Nevertheless, manufacturers that have no solution for these problems could be boxed out of contracts with Section 508-sensitive customers that are looking for SIP-to-the-desktop.
A related consideration is that the Communications and Video Accessibility Act of 2010 (CVAA) bars manufacturers and service providers from charging more for 508-compliant versions of products than is charged for non-compliant configurations. An economical SIP accessibility adjunct, usable with standard unmodified SIP phones, is required.
Some SIP soft clients are able to provide caller ID by voice when used in conjunction with text-to-speech screen-reading adjuncts. Some SIP desktop telephones are able to voice-out the caller ID number (but often not the caller ID name). In residential telephony, voice-output Caller ID adjuncts and stroboscopic alerters are known to sit between the telephone and the phone's connection to the network.
The Section 508 regulations contain many accessibility requirements, a few examples of which are discussed above. An important point is that Section 508 does not impose any limits on the cost of the accommodations. By contrast, the recently enacted CVAA requires manufacturers and service providers to satisfy the Section 508 accessibility requirements without having a significant delta between the cost of the compliant and non-compliant versions of the product.
Illustratively, a SIP desktop telephone that does not have an inherent 508-compliant caller ID module is regarded as satisfying the Section 508 requirements outlined above if the phone can be synchronized with a 508-compliant soft client via a shared control mechanism. However, when one takes into account the complexity and cost of this approach it is apparent that this approach would not satisfy the new CVAA requirements. (Note that, in an enterprise environment, the cost of the PC in a PC-based disability accommodation is not a CVAA consideration. This is because non-disabled employees, not just those with a disability, can be expected to have a PC.)
Assistive caller ID adjuncts, similar to those available for blind and deaf users of residential telephony systems, could be built for SIP systems and may, in fact, already exist. However, because additional special-purpose hardware would be required to satisfy the SIP deskphone requirements, it's not clear that this approach would survive a CVAA audit. At a minimum, a manufacturer or service provider would likely be expected to subsidize the cost of those adjuncts.
Accordingly, a need exists for an inexpensive way to satisfy the regulatory requirements in physical desktop telephones that do not have the support embedded within the standard product.